Benedict John Casey - Page 15

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          manner, in sustaining respondent’s proposed collection action,              
          and accordingly did not abuse her discretion.  See Lunsford v.              
          Commissioner, 117 T.C. 183, 185 (2001).  We sustain respondent’s            
          proposed collection action.                                                 
          VI. Petitioner’s Motion for Sanctions Against Respondent                    
               During trial, petitioner orally moved to impose sanctions on           
          counsel for respondent.  In support of his motion, petitioner               
          asserted vaguely that “it was my belief that all of his                     
          [respondent’s counsel’s] communications were vexatious and, at              
          that time, tactically not in my favor.”  He complained broadly              
          that respondent’s counsel burdened him with an “inundation of               
          paperwork.”  Although the Court invited petitioner to address his           
          motion on brief, petitioner failed to file any brief.                       
               Section 6673(a)(2) allows the Tax Court in its discretion to           
          sanction an attorney admitted to practice before the Court if the           
          attorney has “unreasonably or vexatiously multiplied the                    
          proceedings”.  See Harper v. Commissioner, 99 T.C. 533 (1992)               
          (imposing sanctions under section 6673(a)(2) on the taxpayer’s              
          counsel for repeated and egregious conduct during the discovery             
          process that caused significant delay); Dixon v. Commissioner,              
          T.C. Memo. 2000-116 (imposing sanctions on counsel for the IRS              
          for intentionally misleading the Court).                                    
               Petitioner’s motion for sanctions is without basis or merit.           
          The record does not suggest that respondent’s counsel has engaged           






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